1) This is an action under the Freedom of Information Act (“FOIA”), 5 U.S.C. § 552, to compel production under three separate FOIA requests dated May 8, 2012, seeking certain records pertaining to “secondary”, non-public email accounts for EPA administrators, the existence of which accounts Plaintiff discovered in an Agency document obtained under a previous FOIA request.

2) That Agency memo about these accounts states, “Few EPA staff members, usually only high-level senior staff, even know that these accounts exist.”